UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD DRIVE

ANN ARBOR, MI 48105-2498

OFFICE OF

AIR AND RADIATION

July 28, 2015

MEMORANDUM

SUBJECT: Meeting with Members of the Truck Trailer Manufacturers Association Regarding 

the Proposed Phase 2 Heavy-Duty Greenhouse Gas and Fuel Efficiency Standards

FROM: Jessica Brakora, Engineer, Assessment and Standards Division, Office of 

Transportation and Air Quality

TO: Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and 

Heavy-Duty Engines and Vehicles - Phase 2 - Docket EPA-HQ-OAR-2014-0827

This memo documents a meeting held on July 9, 2015 in Ann Arbor, Michigan between 

representatives of the Truck Trailer Manufacturers Association (TTMA) and EPA to discuss the 

recently-proposed Phase 2 greenhouse gas and fuel efficiency standards for heavy-duty vehicles. 

The six TTMA members attended the meeting and four participated by phone:

– John Freiler, TTMA

– Gary Fenton, Stoughton Trailers

– Justin Bell, Strick Trailers

– Jan Hoover, Strick Trailers

– Sam Guron, Talbert Mfg.

– Shannon Richardson, XL Specialized Trailer

– Andy Grow, East Mfg. Corp. (phone)

– Gary Christian, Etnyre and Co. (phone)

– Charles Fetz, Great Dane Trailers (phone)

– Brian Polgrean, Heil Industries (phone)

The following EPA representatives attended in the meeting:

– Jessica Brakora, Assessment and Standards Division

– Tad Wysor, Assessment and Standards Division

– Charles Moulis, Assessment and Standards Division

– Alan Stout, Assessment and Standards Division

– Stephen Healy, Compliance Division

The following NHTSA representatives participated by phone:

– Maurice Hicks, NHTSA

– Coralie Cooper, Department of Transportation’s Volpe Center
The meeting included a brief overview of the status of the proposed HD Phase 2 program

presented by EPA and attached below. The presentation was followed by a discussion of the 

proposed program elements as outlined in the attached agenda. The meeting concluded with a 

list of items TTMA wished to discuss during a follow-up meeting on July 22, 2015. 

Attachment: 

EPA Trailer Outreach Meeting Agenda

EPA presentation: “TTMA Intro to Proposed Heavy-Duty Rule”
EPA Trailer Outreach Meeting

NVFEL Office Building, 2000 Traverwood Dr, Ann Arbor, MI 48105

July 9th, 2015 – 12:30 to 3:30 Eastern

Conference Line: 1-866-299-3188 // Code: 734-214-4936

AdobeConnect: https://epa.connectsolutions.com/r3mswekq6sa/

AGENDA

* Note that information shared during this meeting will be made public in the docket for the final rule*

12:30 Introductions & Announcements

12:40 Rulemaking Status: Publication in Federal Register on July 13; docket will be available with publication

 60-day comment period begins July 13 and ends September 11, 2015

 Two public hearings will be scheduled in August (Chicago, IL and Los Angeles, CA)

 We will continue to meet with stakeholders and will try to address comments made after formal close of the 

comment period

12:50 What Trailers are covered? (Least to most) – Describe criteria for each category.

 Excluded Trailers – proposed as completely out of the rule

Requesting comment on “exclusion” (no requirements) vs “exemption” (reporting requirement)

 Non-Box Trailers

 Non-Aero Box trailers

 Partial-Aero Box Trailers

 Full-Aero Box Trailers

1:10 Requirements:

Non-Box and Non-Aero trailers

 No aerodynamic requirements

 Design standard for LRR tires & ATIS: requirements that phase in.

Full-Aero Box Trailers

 Phased in CO2 reduction requirements, based on year, length and reefer/dry van design

 Can be met with any combination of aero, LRR tires, ATIS, or weight reduction

Partial-Aero Box Trailers 

 Same requirements as Full-Aero through MY 2026

 Maintain MY 2024 in 2027 and later

Present Table of Requirements.

CO2 (g/ton-mi) to Fuel (gal/1000 ton-mi) conversion.

Discuss EPA model year designation

2:00 Compliance:

Preliminary steps & certification application

Compliance Equation

Inputs: LRR Tires, Aerodynamic Devices, Weight Reduction, ATIS.

Data sources: (1) Pre-approved vendor data and (2) Testing performed by manufacturer

End of year reporting & optional averaging provisions.

(See attached “Memo to Docket” with example compliance scenarios)

3:00 Warranty Requirements: Tires & other devices

3:15 Issues to be discussed further/in detail at our July 22 meeting in Alexandria, VA.

Note: All times are approximate to allow some flexibility of discussion. 

Supplementary materials:

Preamble and Regulation References: “PreambleRegulationReferences.pdf”

Compliance Scenarios: “2015-04-14_MemoToDocket_TrailerComplianceScenarios.pdf”

Small Business Final Panel Report: “2015-01-15_SBREFA_FinalPanelReport_FullDocument.pdf”
TTMA 

Intro to Proposed Heavy-Duty 

Rule

July 9, 2015

Jessica Brakora and Tad Wysor

U.S. Environmental Protection Agency

brakora.jessica@epa.gov, wysor.tad@epa.gov 
Status of the Proposal & Next Steps

• NPRM signed June 19, 2015

– Available on EPA and NHTSA websites

• http://www.epa.gov/otaq/climate/regs-heavy-duty.htm

• http://www.nhtsa.gov/fuel-economy

• Publication expected Monday, July 13

• Docket will be available on www.regulations.gov

on the day of publication

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Providing Feedback

• All meetings and material shared following the NPRM will be 

documented and made public with the FRM

• Expect a 60-day comment period beginning on date of publication

– Written comments are accepted through our dockets, email, or mail 

– We will to respond to written comments made in this comment period

• Two public hearings expected in August

– Comment period will close no less than 30 days after last hearing

– Hearings will be in Chicago, IL and Los Angeles, CA

– Individuals and organizations can provide comments at this time

– We will respond to oral comments made during these hearings 

• We will continue to have meetings and accept feedback until the 

final rule

– We are not required to consider or respond to comments made outside 

of the comment period

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Where can I get more information?

• EPA’s Heavy-Duty Vehicles Webpage

– http://www.epa.gov/otaq/climate/regs-heavy-duty.htm

– Phase 1 and Phase 2 updates

• EPA’s OTAQ Webpage

– http://www.epa.gov/otaq/index.htm

– Sign up for RSS feeds of press releases!

• NHSTA’s Fuel Economy Webpage

– http://www.nhtsa.gov/fuel-economy

– Light-duty and heavy-duty vehicles updates

• Federal Register

– https://www.federalregister.gov/

– Updated daily

• Electronic Code of Federal Regulations (eCFR)

– http://www.ecfr.gov/

– Title 40 for EPA regulations

– Title 49 for NHTSA regulations

• Docket

– http://www.regulations.gov

– EPA Docket: EPA–HQ–OAR–2014-0827 

– NHTSA Docket: NHTSA-2014-0132 

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IF NEEDED

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Four Trailer Inputs for Equation

• Drag Area, Delta CDA

– Result of aerodynamic testing

• Performed by the manufacturer or a contractor

• Performed by aero device manufacturer and results pre-approved by 

EPA/NHTSA

• Tire Rolling Resistance Level, TRRL

– Result of rolling resistance testing

– Generally obtained from tire manufacturer

• ATI

– If you have a qualified system, GEM provides a 1.5% reduction

• Weight Reduction

– List of components that have light-weight options

• Components must be applicable to all box trailers

• Components must not be commonly adopted already

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Performance Measures

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Aerodynamics (Delta CDA, m2)

Bin I 0.0

Manufacturers 

use bin values 

for compliance

Bin II 0.1

Bin III 0.3

Bin IV 0.5

Bin V 0.7

Bin VI 1.0

Bin VII 1.4

Bin VIII 1.8

Tire Rolling Resistance (CRR, kg/ton)

Tire Baseline 6.0 Manufacturers 

use exact CRR

value from tire 

manufacturer

Tire Level 1 5.1

Tire Level 2 4.7

Tire Inflation System (% reduction)

ATI System 1.5 Qualifying 

systems

Weight Reduction (lbs)

Weight1 Weight assigned to 

specific components

Manufacturers

use weight 

from table

Tire Type Material

Weight

Reduction

(lb) 

Wide-Based Single

Steel Wheel 84

Aluminum Wheel 139

Light-Weight Aluminum Alloy Wheel 147

Dual-Wide

High-Strength Steel Wheel 8

Aluminum Wheel 21

Light-Weight Aluminum Alloy Wheel 30

Component Material

Weight

Reduction

(lb)

Suspension Assembly1 Aluminum 280

Hub and Drum (per axle) Aluminum 80

Floor Aluminum 375

Floor Composite 245

Floor Crossmembers Aluminum 203

Landing Gear Aluminum 50

Rear Door Aluminum 187

Rear Door Surround Aluminum 150

Roof Bows Aluminum 100

Side Posts Aluminum 300

Slider Box Aluminum 150

Upper Coupler Assembly Aluminum 430

1 For tandem-axle suspension sub-frames made of aluminum, apply a weight reduction 

of 280 pounds. Use good engineering judgment to estimate a weight reduction for 

using aluminum sub-frames with other axle configurations.

1 1/3 added to payload, 2/3 reduces overall vehicle weight
Equation for Trailer Compliance

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       CO2 C1 C2 TRRL C3 ΔCDA C4 WR C5

CO

       

2

1. Calculate fuel consumption;

2. Submit results to Agencies for 

each trailer family 

3. Obtain certificate of conformity 

prior to production

From Tire 

Manufacturer’s

CRR Testing

From Aerodynamic Testing 

or 

Pre-Approved Devices

Reduction 

Applied if 

ATI Installed

From List of 

Light-Weight 

Components
Illustration of 

Potential Compliance Steps for Trailers

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Summary of 

Potential Box Van Compliance Options

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EPA’s Handling of 

Confidential Business Information (CBI)

Any sensitive information sent to our office would be protected under the federal requirements of the confidential business 

information (CBI) provisions, if it is marked as such. We have controls in place to properly handle any CBI shared by 

companies. In some cases, release of some information may be justified or required, but only pursuant to the regulations at 

40 CFR part 2. The link below is for the electronic Code of Federal Regulations with all the details on how we handle CBI. 

http://www.ecfr.gov/cgi-bin/text-idx?SID=7199a8eb4e6113ccc8ffaf81560e66ca&tpl=/ecfrbrowse/Title40/40cfr2_main_02.tpl

When we publish proposed rules, we always include clear guidelines on how to submit CBI to EPA. Below is an excerpt of the 

guidelines that were included when we proposed the HD GHG Phase 1 rule in 2011: 

All comments received will be included in the public docket without change and may be made available online at 

www.regulations.gov, including any personal information provided, unless the comment includes information claimed to be 

Confidential Business Information (CBI) or other information whose disclosure is restricted by statute. Any CBI submitted to 

one of the agencies will also be available to the other agency. 

This statement constitutes notice to commenters pursuant to 40 CFR 2.209(c) that EPA will share confidential business 

information received with NHTSA unless commenters expressly specify that they wish to submit their CBI only to EPA and not 

to both agencies. However, as with all public comments, any CBI information only needs to be submitted to either one of the 

agencies’ dockets and it will be available to the other. Following are specific instructions for submitting CBI to either agency. 

Clearly mark the part or all of the information that you claim to be CBI. For CBI in a disk or CD-ROM that you mail to EPA, 

mark the outside of the disk or CD-ROM as CBI and then identify electronically within the disk or CD-ROM the specific 

information that is claimed as CBI. In addition to one complete version of the comment that includes information claimed as 

CBI, a copy of the comment that does not contain the information claimed as CBI must be submitted for inclusion in the public

docket. Information so marked will not be disclosed except in accordance with procedures set forth in 40 CFR part 2. 

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EPA’s Regulatory Definition of 

Good Engineering Judgment

§1068.30 What definitions apply to this part?

Good engineering judgment means judgments made consistent with generally accepted scientific and 

engineering principles and all available relevant information. 

§1068.5 How must manufacturers apply good engineering judgment?

(a) You must use good engineering judgment for decisions related to any requirements under this chapter. 

This includes your applications for certification, any testing you do to show that your certification, productionline, and in-use engines/equipment comply with requirements that apply to them, and how you select, 

categorize, determine, and apply these requirements.

(b) If we send you a written request, you must give us a written description of the engineering judgment in 

question. Respond within 15 working days of receiving our request unless we allow more time.

(c) We may reject your decision if it is not based on good engineering judgment or is otherwise inconsistent 

with the requirements that apply, based on the following provisions:

(1) We may suspend, revoke, or void a certificate of conformity if we determine you deliberately used 

incorrect information or overlooked important information, that you did not decide in good faith, or that your 

decision was not rational.

(2) If we believe a different decision would better reflect good engineering judgment, but none of the 

provisions of paragraph (c)(1) of this section apply, we will tell you of our concern (and its basis). You will have 

30 days to respond to our concerns, or more time if we agree that you need it to generate more information. 

After considering your information, we will give you a final ruling. If we conclude that you did not use good 

engineering judgment, we may reject your decision and apply the new ruling to similar situations as soon as 

possible.

(d) We will tell you in writing of the conclusions we reach under paragraph (c) of this section and explain our 

reasons for them.

(e) If you disagree with our conclusions, you may file a request for a hearing with the Designated Compliance 

Officer as described in subpart G of this part. In your request, specify your objections, include data or 

supporting analysis, and get your authorized representative's signature. If we agree that your request raises a 

substantial factual issue, we will hold the hearing according to subpart F of this part.

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Definition of model year

• 40 CFR 1037.801 

– “Model year means the manufacturer’s annual new model 

production period, except as restricted under this definition and 

40 CFR part 85, subpart X. It must include January 1 of the 

calendar year for which the model year is named, may not begin 

before January 2 of the previous calendar year, and it must end 

by December 31 of the named calendar year.”

• 40 CFR 85 subpart X: 

– Definition of model year. Model year means the 

manufacturer's annual production period (as determined under 

§85.2304) which includes January 1 of such calendar year, 

provided, that if the manufacturer has no annual production 

period, the term “model year” shall mean the calendar year.

– Duration of model year. A specific model year must always 

include January 1 of the calendar year for which it is designated 

and may not include a January 1 of any other calendar year. 

Thus, the maximum duration of a model year is one calendar 

year plus 364 days.

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